October 2011 1-1 Module 1: Regulations - The RRP Rule Addresses activities that disturb lead-based paint in target housing and child-occupied facilities.

October 2011 1-1

Module 1: Regulations - The RRP Rule• Addresses activities that disturb lead-based paint in

target housing and child-occupied facilities. It requires:• Renovators to be certified through training.• Firms to be certified.• Training providers to be accredited.• Lead-safe work practices during renovations.• Pre-renovation education in target housing and child-occupied

facilities.

• Firms working in pre-1978 homes and child-occupied facilities must be certified and use lead-safe work practices during renovations.

• EPA may authorize states, territories and tribes to enforce the Rule.

October 2011 1-2

The RRP Rule: Exclusions

• Renovation activities where affected components do not contain lead-based paint.

• Emergency renovations (requires cleanup and cleaning verification).

• Minor repair and maintenance activities. Note: This does not apply to window replacement, demolition or activities involving prohibited practices.

• Renovations performed by homeowners in their own homes.

October 2011 1-3

The RRP Rule: Firm Certification

• To become certified, firms must submit an application and fee to EPA.

• Certifications will be good for 5 years.• Certification allows the firm to perform

renovations in any non-authorized state or Indian tribal area.

October 2011 1-4

The RRP Rule: Firm Responsibilities

• Ensure overall compliance with the RRP Rule.• Ensure that all renovation personnel are Certified

Renovators or have been trained on-the-job by Certified Renovators.

• Assign a Certified Renovator to all jobs.• Meet Pre-Renovation Education Requirements.• Meet recordkeeping requirements.

October 2011 1-5

The RRP Rule: Individual Certification

• To become a Certified Renovator, an individual must either take an EPA-approved 8-hour training course, or for those with previous training an EPA-approved 4-hour training course, from an EPA-accredited training provider.

• The course completion certificate serves to certify renovators (no application to EPA is required).

• Refresher training is required every 5 years.• Workers do not need certification so long as on-the-job

training is received from a Certified Renovator and the work is not HUD-regulated.

October 2011 1-6

The RRP Rule: Certified Renovator Responsibilities• Perform work and direct lead-safe work practices.• Provide applicable on-the-job training to non-certified workers.• Keep a copy of initial and/or refresher training certificates onsite. • When requested, conduct testing for lead-based paint using EPA-

recognized test kits or collect paint chip samples for lab analysis and report findings.

• Be physically present while posting signs, containing work areas, and cleaning work areas.

• Be available by telephone when off-site.• Maintain the containment to keep dust and debris within the work

area.• Implement the cleaning verification procedure.• Prepare and maintain required records.

October 2011 1-7

Pre-Renovation Education Requirements

• The RRP Rule updated the Pre-Renovation Education Rule. This slide summarizes the changes.

• Renovation firms must provide the new Renovate Right pamphlet (Appendix 3) to owners and occupants of target housing before renovation starts.

• In a child-occupied facility, Renovate Right must be provided to the owner or an adult representative before renovation.

• For work in common areas of multifamily housing or child-occupied facilities, firms must notify tenants or parents/guardians of the children, or post informational signs about the renovation or repair.

• See the Compliance Guide (Appendix 4) for more information.

October 2011 1-8

The RRP Rule: Work Practice Standards

The Renovation, Repair, and Painting Final Rule covers setup of the work area, prohibited work practices, cleanup and the cleaning verification procedures.• Setup practices, such as posting signs and containing

the work area, will be covered in Module 3.• Prohibited practices and dust control will be covered

in Module 4.• Cleanup practices and cleaning verification

procedures will be covered in Module 5.• Recordkeeping will be covered in Module 6.

October 2011 1-9

The RRP Rule: Enforcement

• EPA may suspend, revoke, or modify a firm’s certification if the Certified Firm or Certified Renovator is found to be in non-compliance.

• Those firms found to be non-compliant may be liable for civil penalties for each violation.

• Those firms who knowingly or willfully violate this regulation may be subject to additional fines per violation, or imprisonment, or both.

October 2011 1-10

HUD’s Lead Safe Housing Rule (LSHR)• Covers target HOUSING that is

Federally-owned or assisted. • Does not cover child-occupied facilities.• Key differences between the LSHR and

the RRP Rule are shown in text boxes with the HUD logo.

• See Appendix 2 for a complete discussion of additional requirements imposed by the LSHR on Certified Renovators working in Federally-assisted target housing.

October 2011 1-11

State and Local Regulations

• States and localities may have different regulations than EPA and HUD for renovations in target housing.

• Check with your state and local housing and environmental agencies to obtain information about such requirements.

• Appendix 7 is reserved for copies or summaries of state and local regulations.

October 2011 1-12

Know the Rules!

To obtain a copy of the EPA or HUD regulations contact the National Lead Information Center at 1-800-424-LEAD or download them from the following websites:

• http://www.epa.gov/lead• http://www.hud.gov/offices/lead

U.S. Occupational Safety and Health Administration (OSHA):

• Establishes worker protection standards. • For more information, on the OSHA Lead in

Construction Standard, see http://www.osha.gov/Publications/osha3142.pdf.

State and local regulations: • Renovators must follow all applicable state and local

regulations during renovations.